Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The Eighth Circuit reversed the district court's adverse grant of summary judgment in favor of Metro Transit in an action brought by plaintiff, who is blind and deaf, alleging claims under the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Minnesota Human Rights Act (MHRA). In this case, plaintiff's claims stemmed from 150 complaints he made regarding bus operators' failure to stop at T-Signs and announce the bus route. The court concluded that the record contains evidence sufficient to raise a genuine issue of material fact as to whether Metro Transit provided meaningful access to disabled bus riders. The court stated that, at trial, the DOT regulations cited by plaintiff are admissible as evidence that the jury may consider and weigh when determining whether he has met his burden of demonstrating that he was denied meaningful access to Metro Transit's services. View "Segal v. Metropolitan Council" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment in favor of Bi-State in an action brought by plaintiff under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court concluded that the district court did not abuse its discretion in determining that plaintiff's claims regarding federal transportation regulations were barred by judicial estoppel where his position on summary judgment is inconsistent with the position he took on Bi-State's motion for a judgment on the pleadings; he persuaded the district court that he was not pursuing a private right of action under the federal regulations; and allowing him to take an inconsistent position would give him an unfair advantage in the litigation.The court rejected plaintiff's argument that the district court erred when it determined his claims were barred by the previous settlement agreement and, alternatively, granted summary judgment to Bi-State on the merits. The court concluded that, even assuming the agreement does not bar plaintiff's claims, those claims would still fail because he cannot demonstrate that Bi-State denied him meaningful access to its services. In this case, plaintiff has not shown he was denied an opportunity to access the same services as non-disabled riders. Finally, the court concluded that it lacked jurisdiction to review the denial of plaintiff's motion to amend the complaint. View "Gustafson v. Bi-State Development Agency" on Justia Law

The Eighth Circuit affirmed the district court's revocation of supervised release and imposition of a three year prison sentence. The court concluded that the district court did not impermissibly lengthened defendant's sentence so he could participate in a sex offender treatment program, in violation of Tapia v. United States, 564 U.S. 319, 335 (2011). In this case, the district court based its sentencing decision on the danger defendant posed to children in the community and the fact that his continued violations showed he was not amenable to supervision. Finally, the court concluded that defendant's sentence was not substantively unreasonable where the district court considered the 18 U.S.C. 3553(a) sentencing factors and did not err in imposing the statutory maximum. View "United States v. Smith" on Justia Law

The Eighth Circuit agreed with the district court that an automated marketing system that sends promotional text messages to phone numbers randomly selected from a database of customers' information is not an automated telephone system (an Autodialer) under the Telephone Consumer Protection Act (TCPA). Plaintiffs, persons who received promotional text messages from defendants through their marketing software called Txt Live, allege that these messages violated the TCPA because they were sent using an Autodialer without plaintiffs' consent. The court affirmed the district court's grant of summary judgment in favor of defendants, holding that Txt Live did not meet the statutory definition of an Autodialer. View "Beal v. Outfield Brew House, LLC" on Justia Law

The Eighth Circuit affirmed defendant's sentence for accessing the internet with intent to view child pornography. The court concluded that defendant's within-Guidelines sentence of 48 months in prison was not substantively unreasonable where the district court did not commit a clear error of judgment or abuse its substantial sentencing discretion in weighing the 18 U.S.C. 3553(a) sentencing factors. View "United States v. Anderson" on Justia Law

The Eighth Circuit affirmed defendant's conviction for sexual exploitation of a child and possession of child pornography. Any error in admitting an expert witness's testimony comparing finger and knuckle creases in sexually explicit photos with photos of defendant's fingers and knuckles was harmless in light of the overwhelming evidence of defendant's guilt. View "United States v. Red Legs" on Justia Law

The Eighth Circuit affirmed the district court's order denying defendant's motion for reduction of sentence under 18 U.S.C. 3582(c)(1)(A). The court concluded that the district court did not err in concluding that defendant failed to present extraordinary and compelling reasons for a reduction. The court also concluded that a non-retroactive change in law, whether offered alone or in combination with other other factors, cannot contribute to a finding of extraordinary and compelling reasons for a sentence reduction. U.S. v. Crandall, 25 F.4th 582, 586 (8th Cir. 2022). View "United States v. Taylor" on Justia Law

After plaintiff filed a motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255, the district court dismissed most of his claims but granted a certificate of appealability on whether plaintiff's attorney failed to file a direct appeal despite instructions to.The Eighth Circuit affirmed, concluding that the district court's factual finding—that plaintiff did not direct counsel to file a notice of appeal within 14 days of sentencing—was based on a reasonable credibility determination. On the record, the court found no clear error in the finding that plaintiff did not instruct his attorney to file a notice of appeal within the deadline for doing so. View "Dressen v. United States" on Justia Law

The Eighth Circuit denied petitions for review of the BIA's decision denying petitioner's application for cancellation of removal. The court concluded that, while the BIA's decision is no model of clarity and is disappointingly conclusory, it recited the appropriate standards of review. The court had no reason to conclude that the BIA did not follow these standards and reviewed the IJ's findings of fact for clear error and ultimate legal determination of good moral character de novo. Finally, petitioner's contention that the BIA failed to provide a reasoned basis for denying his motion to remand is belied by the record. View "Dominguez Hernandez v. Garland" on Justia Law

The Eighth Circuit affirmed defendant's conviction for production and attempted production of child pornography and extortion. The court concluded that the district court did not err by refusing to admit a text message confession as unreliable, and the extrinsic evidence lacked probative value and was not relevant. The court also concluded that there was no error in limiting defendant's use of the evidence under Federal Rule of Evidence 613(b).The court rejected defendant's Batson challenge and concluded that the district court did not clearly err in finding that the government's race-neutral reason was not pretextual; the district court did not clearly err in finding that PJ 5's equivocation and indecisiveness regarding whether she could follow the law was a nondiscriminatory race-neutral reason for the strike; and the district court did not clearly err in finding these were nondiscriminatory race-neutral reasons to strike PJ 14. Finally, the court concluded that the district court did not abuse its discretion in denying defendant's motion to strike. View "United States v. Cumbie" on Justia Law